SFDR's entity-level disclosures must be published on the firm's website. This is not simply a channel-of-publication requirement, the website is the primary anchor point for SFDR transparency, and the regulation and RTS set specific requirements for content, presentation, accessibility, and maintenance of website disclosures.
In plain English: it is not enough to have good internal sustainability policies. You must put them on your website in a way investors can actually find and understand.
The Website as the Primary Disclosure Medium
SFDR uses the firm's website as the primary channel for entity-level disclosures (Articles 3-5) and for certain product-level disclosures (Article 10). The choice of website publication reflects the regulation's aim to make sustainability information publicly accessible, comparable, and verifiable, investors, regulators, and the public can review and compare disclosures without requiring a pre-existing commercial relationship.
The ESMA Q&As (Q&A I.4, published 25 July 2024) address a practical question: what if a registered (sub-threshold) AIFM has no website? The answer is clear: the AIFM must establish a website in order to comply with Article 10 of SFDR. If no website exists, the firm must create one. The website information must be easily accessible to investors, kept up to date, and changes must be clearly explained (see Recital 26 and Article 12 of SFDR, and Article 2 of the SFDR Delegated Regulation). The firm may use the website of a group to which it belongs, if that website corresponds to the AIFM's own website.
Article 3, Sustainability Risk Integration Policy
The sustainability risk integration policy required by Article 3 must be published on the website with:
Accessibility: The policy must be easily findable on the website, typically on a dedicated "Sustainability" or "ESG" page, or within an "About Us" or "Regulatory Information" section. Burying it several clicks deep from the homepage, or including it only in a downloadable legal document, would be insufficient.
Clarity: The policy should be written in plain language accessible to an informed retail investor, not only to institutional specialists.
Currency: The policy must be kept up to date. If the firm changes its sustainability risk integration approach, the website policy must be updated accordingly, and any revisions should be clearly explained (Article 12 of SFDR).
Completeness: The policy must address all four required elements: identification, assessment, integration into decisions, and expected impact on returns.
Article 4, PAI Statement
The PAI statement (for firms above the 500-employee threshold or that opt in) must be published on the website in a dedicated section titled "Statement on principal adverse impacts of investment decisions on sustainability factors". This exact title is required, it should be clearly labelled so that investors can find it without ambiguity.
For firms that do not consider PAI (comply-or-explain), the website must contain a clear statement explaining why PAI are not considered and, where relevant, whether and when the firm intends to consider them.
The PAI statement must include a summary in at least two languages: one language customary in international finance (English), and at least one official language of each Member State where the firm's financial products are made available. This multilingual requirement reflects the cross-border nature of the EU investment market.
Article 5, Remuneration Policy
The remuneration policy information must be accessible on the website, typically as part of or linked from the main remuneration policy publication. It does not need to be a separate standalone document, but the sustainability risk consistency content must be clearly identifiable within whatever document structure the firm uses.
Article 10, Product-Level Website Disclosures
Beyond entity-level content, Article 10 requires FMPs to publish on their website specific information for each Article 8 and Article 9 product they make available. This product-level website disclosure must include:
- A description of the environmental or social characteristics or the sustainable investment objective
- Information about the methodologies used to assess, measure, and monitor those characteristics or the investment objective
- The data sources used
- Screening criteria applied (if any)
- Relevant sustainability indices used as reference benchmarks
- Information on good governance practices of investee companies
The RTS specifies that this product-level website information should be presented in a format that allows investors to compare it with the pre-contractual disclosures and periodic reports for the same product. Recital 24 of the RTS emphasises that the website should expand on topics disclosed concisely in pre-contractual documents, providing fuller information for investors who want to dig deeper.
The pre-contractual disclosure (prospectus or KID) is like the brief product summary on a product label. The website disclosure is like the detailed product page that gives you the full specification sheet, how it was made, what the ingredients are, what tests it passed. The periodic report is like the annual review of how the product actually performed. All three should be consistent, but each serves a different purpose and level of depth.
RTS Requirements for Website Content Structure
The RTS (Article 2 of the Delegated Regulation) requires that website disclosures be:
- Accurate and not misleading: Content must not create a false impression of a product's sustainability characteristics or a firm's sustainability approach
- Clear and not technical to the point of incomprehensibility: Plain language principle applies
- Concise on the website, with fuller detail available through links: Where space is limited (e.g., product-level summaries), hyperlinks to fuller information are acceptable
- Kept up to date: Any revisions must be clearly indicated with the date of the revision and an explanation of the change
- Archived: Previous versions should be accessible, so investors can track changes over time
Hyperlink from Pre-Contractual Documents
Article 12 of SFDR requires that pre-contractual documents for financial products include a hyperlink to the relevant website section where additional sustainability information can be found. This creates a chain: the brief pre-contractual disclosure links out to the richer website disclosure, which in turn links to periodic reports and other supporting documents.
Example, Website structure for a mid-size UCITS manager with three Article 8 funds:
Homepage navigation path: Home → Sustainability → [three sub-sections]
Sub-section 1: Our Sustainability Approach (entity-level, Article 3)
- Sustainability Risk Integration Policy (PDF + summary)
- PAI Statement, 2023 reference period (PDF, Article 4)
- Remuneration Policy, Sustainability Consistency Statement (Article 5)
Sub-section 2: Fund Sustainability Disclosures (product-level, Article 10)
- [Fund A Name], Article 8 Disclosure
- [Fund B Name], Article 8 Disclosure
- [Fund C Name], Article 8 Disclosure Each fund has its own page with methodology, data sources, sustainability indicators, and a link to the pre-contractual document and latest periodic report.
Sub-section 3: EU Taxonomy Information
- Explanation of Taxonomy alignment methodology
- Product-specific Taxonomy alignment figures (linked from fund pages)
Real-world example: Amundi's sustainability website section follows broadly this pattern, with entity-level policies, product-level Article 8/9 disclosures, and PAI statements all accessible from a central hub.
Review and Maintenance Obligations
Firms must review website disclosures regularly. There is no statutory prescribed review interval for most disclosures, but best practice (and NCA expectations) is at least annual review, with interim updates triggered by:
- Changes to investment strategy or ESG integration approach
- Changes to product classification (e.g., a product reclassified from Article 9 to Article 8)
- New or updated regulatory requirements
- Material changes to PAI indicator data methodologies
- Changes to reference benchmarks or sustainability indices
Documentation of the review process is important for demonstrating compliance to supervisors.
Common Website Compliance Failures
Based on NCA reviews and supervisory observations:
- Disclosures buried in legal documents: Publishing sustainability content only inside a fund prospectus or supplement, without a dedicated website section, does not meet Article 10
- Outdated content: PAI statements or product disclosures that have not been updated to reflect the RTS templates or changes in investment strategy
- Template violations: Pre-RTS format disclosures for Article 8/9 products that have not been updated to use the standardised Annexes required from January 2023
- Missing products: Website disclosures that cover some but not all Article 8 or 9 products in a firm's range
- Inconsistency: Website disclosures that are materially inconsistent with the pre-contractual documents for the same product
Key Takeaways
- 1The firm's website is the primary anchor for entity-level disclosures (Articles 3-5) and product-level disclosures (Article 10) - if no website exists, one must be created
- 2The PAI statement must be published under the exact title 'Statement on principal adverse impacts of investment decisions on sustainability factors' with a multilingual summary
- 3Article 10 product-level website disclosures must cover methodology, data sources, screening criteria, and sustainability indices for each Article 8 and 9 product
- 4Pre-contractual documents must hyperlink to the relevant website section, creating a chain from brief disclosure to detailed methodology to periodic reporting
- 5Website disclosures must be kept up to date, with changes clearly explained and dated - previous versions should remain accessible for investor tracking
- 6Common failures include burying disclosures in legal documents, using pre-RTS formats after January 2023, and missing products from the website disclosure set